Comment from Jean Public

Document ID: CPSC-2012-0036-0003
Document Type: Public Submission
Agency: Consumer Product Safety Commission
Received Date: June 30 2012, at 12:00 AM Eastern Daylight Time
Date Posted: August 1 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: June 29 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: September 12 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 81073c8b
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RABBITS SHOUDL BE TAKEN FROM THE LIST OF ANIMALS THAT ARE USED FOR ANY TESTING. NO MORE RABBITS SHOULD BE USED AT ANY TIME. ALSO THI SCHANGE SHOULD REFLECT THAT THIS AGENCY PREFERS OTHER TEST METHODS THATN ABUSIVE TESTS ON ANIMALS. TESTS ON HUMAN CELLS OR ONPEOPLE ARE PREFERRED. IT IS ALSO CLEAR THAT TESTS TESTS ON ANIMALS ARE DECEPTIVE AND NOT REALLY RELEVANT OR MEANINGFUL IN APPLICATION TO WHAT THE PRODUCT WILL DO TO A PERSON. AGAIN, GET THE RABBITS ENTIRE OUT OF THIS TESTING CYCLE. THIS TEST METHOD STARTED IN MIDIEVEL TIMES 1500 AD. WE HAVE MUCH MORE RELIABLE METHODS OF TESTING TODAY THAN ABUSING AND PAINFULLY INJURING AND KILLING RABBITS. More rabbits are used for research in the U.S. than any other covered species. In 1987, an all-time high of 554,385 rabbits were exploited for research and testing. Over the past two decades, rabbit use has gradually declined, with the latest reports indicating that over 200,000 rabbits are utilized annually. Rabbits are widely used for experimentation and testing mainly due to practical rather than scientific considerations. They are small and usually docile, easily restrained, cheap to maintain, and breed prodigiously. Most people associate the use of rabbits in laboratories with toxicity testing for cosmetic, personal, and household products. The best known tests are the Draize eye and skin irritancy tests, which are extremely painful and cruel. While being experimented upon, rabbits are also often locked into full-body restraints to prevent them from touching eye or skin sores. These tests are not very reliable, and increasing attention is being paid to the development of alternatives to replace the use of rabbits for these categories of toxicity testing. For medical products such as vaccines, drugs, and medical devices, rabbits are used to test pyrogenicity (the ability of the product to induce a fever). Additionally, because of their high rate of reproduction, rabbits are also used to test developmental/embryotoxi

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